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Commerce, Treasury, and State Announce Measures Targeted at Further Restricting Russia and Belarus

On August 23, 2024, the U.S. Departments of Commerce, Treasury, and State published new restrictions on Russia aimed at further limiting its access to U.S. materials and international procurement networks for its military....more

New Export Control Compliance Resources for Academic Institutions

On August 14, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued two new resources for academic institutions to help them navigate and comply with export controls. These come in the form of a...more

OFAC Publishes Guidance on Extension of Statute of Limitations and Recordkeeping Requirements

On July 22nd, 2024, OFAC published a guidance document regarding the 21st Century Peace through Strength Act’s extension of the statute of limitations for civil and criminal violations of the International Emergency Economic...more

Commerce Initiates Rulemaking Targeting Foreign-Manufactured Technology Used In Connected Vehicles

On Thursday, February 29th, 2024, the Department of Commerce (“the Department”) announced an advance notice of proposed rulemaking (“ANPRM”), seeking public comments regarding new potential regulations to ​“secure and...more

2nd Anniversary of Ukraine Invasion Brings New Sanctions on Russia

On February 23, 2024, on the 2nd anniversary of Russia’s invasion of Ukraine, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced significant new sanctions, adding nearly 300 Russian and select...more

Commerce Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

BIS Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

BIS Hits Wabtec Corporation with $153,175 Civil Penalty for Antiboycott Violations

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (“BIS”) announced a settlement with Wabtec Corporation of $153,175 for violations of the antiboycott provisions of the Export Administration...more

BIS Clarifies Notification and Licensing Requirements for Updated Semiconductor, Advanced Computing Export Controls

On December 29, 2023, the Commerce Department’s Bureau of Industry and Security (BIS) issued Frequently Asked Questions (FAQs) concerning the agency’s recently updated semiconductor and advanced computing export controls. In...more

White House Broadens Restrictions on Russia by Authorizing Sanctions on Foreign Financial Institutions and Expanding the Import...

On December 22, 2023, President Biden signed Executive Order 14114, titled ​“Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” (EO 14114), with a focus on holding foreign financial...more

Commerce Department Proposes to Ease Licensing Requirements for Strategic Trade Authorization

On December 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a proposed rule to amend License Exception Strategic Trade Authorization (“STA”) within the Export Administration...more

House 90-Day Review Report Calls for “Win-At-All-Costs” Approach to Preventing PRC Access to Critical U.S. Technology

On December 7, 2023, the U.S. House of Representative’s Foreign Affairs Committee (House Committee) released a 90-day report (the Report) on the Commerce Department’s Bureau of Industry and Security (BIS). The report lays...more

Treasury Department Announces Largest Settlement in History and Severe Penalties Against Binance

On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more

U.S. Temporarily Eases Sanctions Against Venezuelan Energy, Gold

On October 18, the Treasury Department’s Office of Foreign Assets Control (OFAC) eased U.S. sanctions on dealings with Venezuela’s gold and oil and gas sectors by issuing and amending several general licenses. According to...more

U.S. Bureau of Industry and Security Creates Option for Extended Renewals of Temporary Denial Orders

On August 30, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to allow for the extended renewal of Temporary Denial Orders (“TDOs”) under...more

White House Issues Executive Order on Outbound Investment Screening

On August 9, 2023, the White House issued Executive Order 14105 (“EO”) to address the national security threat posed by outbound investment in certain countries of concern that seek to develop and exploit sensitive or...more

Senate Bill Proposes to Curb Export Licenses and Impose “Flow Down” Entity List Restrictions

On June 22, 2023, Senators Rubio (R-FL) and Wicker (R-MS) – the top Republicans on the Select Committee on Intelligence and the Armed Services Committee, respectively – introduced S. 2170, the Depriving Enemy Nations of...more

OFAC Issues Africa Gold Advisory

On June 27, 2023, the Treasury Department’s Office of Foreign Assets Control (“OFAC”), in conjunction with USAID, and the Departments of Commerce, Homeland Security, and Labor, published an Africa Gold Advisory identifying...more

OFAC Settlement Highlights Need for Compliance Training Across Subsidiaries for Multinational Firms

The Office of Foreign Assets Control (“OFAC”) recently announced a settlement agreement with Danfoss A/S (“Danfoss” or “the company”) in response to allegations that Danfoss directed its customers in Iran, Syria, and Sudan to...more

Initial Restructuring of the International Traffic in Arms Regulations

As part of a comprehensive streamlining effort, the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) issued an interim final rule that reorganizes and restructures Part 120 of the International Traffic in...more

CFIUS Issues New Enforcement and Penalty Guidance

On October 20, the Committee on Foreign Investment in the United States (CFIUS or the Committee) issued a press release laying out new guidance to provide clarity about how the Committee assesses violations of the laws and...more

Biden Administration Issues Executive Order Defining Additional National Security Considerations for CFIUS

On September 15, President Biden signed an Executive Order (EO) with the first ever formal Presidential direction to the Committee on Foreign Investment in the United States (CFIUS or the Committee). The EO emphasizes the...more

Commerce Department Significantly Expands Export Controls on Russia and Belarus; Limits Exceptions for Belarusian Aircraft

In a rule change that was effective April 8, 2022, but communicated on April 11, 2022 the Commerce Department’s Bureau of Industry and Security (BIS) expanded coverage of export controls on Russia and Belarus to include any...more

Summary of Sanctions Imposed on Russia This Week (March 11, 2022)

It has been almost three weeks since the U.S. and its allies began imposing serious new sanctions and export control restrictions on Russia and Belarus in response to Russia’s invasion of Ukraine. This post summarizes the...more

More Sanctions on Russia: Import Bans, Revocation of MFN Status, Luxury Goods Ban, USD Ban, Other Measures

In coordination with the European Union and G7 countries, the United States announced a raft of new sanctions and trade control measures targeting Russia today in response to the ongoing war in Ukraine. The new measures...more

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